THE SECRETARY OF TRANSPORTATION WASH I NGTON, D.C. 20590

The Honorable Paul Cook U.S. House of Repre sentati ves Washington, DC 20515 Dear Congressman Cook: April 04, 2014

Thank you for your letter regarding the application ofNorwegian Air International Limited (NAI) for authority to conduct U.S. service s. Given that a number of interested parties have filed responsive pleadings to NAI's application and this matter is currently pending before the Department, I am sure yo u understand that I cannot comment on the merits ofNAI ' s application. I assure you, however, that we will give full and careful consideration to all of the pleadings filed on the record before we reach a determination in this matter. As is our standard practice , I am placing a copy ofyour letter and my response in Docket DOT-OST-2013-0204 , as a contact outside the record ofthis case. You may track the progress ofthis case and view the publicly available documents filed in the docket by accessing the Federal Docket Management System at www.regulations.gov and sea rching for Docket DOT-OST-2013-0204. I hope this information is helpful. Sincerely,

Anthony R. Foxx

### . PAUL COOK 8TH DISTRICT. CALIFORNIA

February 10,2014

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The Honorable Anthony Foxx Secretary U.S. Department ofTransportation 1200 New Jersey Avenue SE Washington, D.C. 20590 1222 LONGWORTH HOUSE OFFICE**8UILOI~G** WAS III NGTON, D C 20515 (202) 225-5861

Re: Application of Norwegian Air International Limited, Docket DOT-OST-2013-0204. Dear Secretary Foxx, I am writing to express my deep concern over the application before your Department by Norwegian Air International Limited (NAI) for exemption authority and a foreign air carrier permit. Approval of this application would not be in the public interest for the reasons I explain below. Behind the NAI application lies a global outsourcing business model for its pilots and flight attendants (or "aircrew") that will put U.S. airlines and their employees at a competitive disadvantage. Indeed, this airline bearing the name "Norwegian" describes itself in the application as "a foreign carrier oflreland." NAI's application provides little information about itselfor its plans , but from media reports it appears to be in the same corporate family 

### with another carrier, a rapidly-growing low-cost airline , Norwegian Air Shuttle (NAS). For one thing, the CEO ofNAI, named in the application as Asgeir Nyseth, is the Chief Operating Officer of NAS. For another, NAI is seeking an operating license from Irish aviation authorities, a step that NAS previously signaled 

### in the media it would take. The cause ofmy deep concern is NAS' publicly-stated desire to avoid the obligations of Norwegian labor law. NAS has stated that, to conduct its new long-haul operations, including those to the U.S., it will seek to register its aircraft in, and receive an air operator's certificate from, a European Union country whose labor laws, unlike Norway's, will allow outsourcing of aircrew beyond the EU. NAS/NAI has chosen Ireland. NAS has stated that it plans to operate this Irish subsidiary-registered aircraft to fly from Norway and other EU points to the United States with outsourced lower-wage aircrew, based in Southeast Asia, under individual employment contracts governed by Singapore law. It appears that NAS may now intend to use NAI as its Irish affiliate to bring its plan to fruition. NAl!NAS's business model is designed expressly to undermine fair wages and working conditions. It would also put U.S. carriers who have to compete against it at a competitive disadvantage. Accordingly, approval ofNAI's application for authority would be inconsistent



# s 10- 140220-0 17 PRINTED ON RECYCLED PAPERwith the Congressionally-established public interest as set forth in the aviation statutes . Thank you for your consideration. Sincerely,

# IJ~ Col. Paul Cook (Ret.) Member ofCongress



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